AQ_F_0900009_20201211_ST_RvwMemo

Division of Air Quality
December 11, 2020
MEMORANDUM
To: Heather Carter, Fayetteville Regional Supervisor
From: Gary L. Saunders, Stationary Source Compliance Branch
Subject: The Chemours Company—Fayetteville Works
Fayetteville, Bladen County, North Carolina
Facility ID. No.0900009, Permit No. 03735T47
Performance Testing for HFPO Dimer Acid Conducted on September 1, 2020
at Vinyl Ethers South (VES) Carbon Bed by O'Brien & Gere, Inc.
Tracking No. 2020-310ST
Summary of HFPO Dimer Acid Test Program
Sources Tested
The VES carbon bed adsorber was sampled on September 1, 2020. The carbon bed adsorber was
returned service for controlling fugitive emissions from "room air" at the VES production area after the
thermal oxidizer became operational. Testing was conducted to determine removal efficiency and
emission rates from the VES fugitive emissions and controls.
Sampling Method
Testing was conducted using a modified EPA Method 0010 found in the SW-846 compendium of Test
Methods far Evaluating Solid Waste:Physical/Chemical Methods. This sampling train is a variation of the
EPA Reference Method 5 found in 40 CFR 60,Appendix A. The Method 0010 train extracts a sample
isokinetically from the gas stream, passes the sample through a temperature-controlled filter,through a
temperature-controlled condenser and into a series of XAD-2 resin "traps" and impingers to capture and
collect the materials that passed through the filter. The test method is designed to capture certain
particulate and condensable materials for later recovery and analysis.
After sample recovery,the samples were sent to Chemours' contractor,Test America's laboratory in
Denver, Colorado. HFPO Dimer Acid was extracted from the resin traps. This summary of results only
addresses the results provided by Eurofins(Test America) for Chemours. Laboratory analysis and
quantification was performed using a liquid chromatography column and a dual mass spectrometer
(LC/MS/MS).
Test Results
The reported HFPO Dimer Acid test results reflect corrected emission rates accounting for dilution and
spike recovery values.

Vinyl Ethers South Area Test Results
Inlet and outlet emissions from the VES carbon bed adsorber were measured on September 1, 2020 to
determine the removal efficiency of HFPO Dimer Acid from the process room air emissions. Each test
run was nominally 90 minutes in length. The process was operating normally and was producing PMVE
and PEVE.
The report incorrectly references a contamination issue for XAD-2 Breakthrough Resin Trap for Run 1.
The analytical data does not support this an NC DAQ believes that this report inadvertently confuses the
analytical results for the VEN test during this test series. NC DAQ did note a higher value than expected
for the XAD-2 Breakthrough Resin Trap value for the Run 3 outlet run. However,this higher than
expected value was not subtracted out from the total HFPO Dimer Acid revered in the sample train.
Table 1. Summary of Stack Test Results for VES Carbon Bed on September 1,2020
HFPO Dimer Acid Emission Rate
Run Number Inlet Outlet % Removal Efficiency
(lb/hr) (lb/hr)
1 2.44E-04 1.46E-04 40.16
2 4.86E-04 1.75E-04 *NA
3 3.26E-04 1.44E-04 55.83
Average 3.52E-04 1.55E-04 55.97
*Not Applicable as the removal efficiency was negative.
Summary and Conclusions
NC DAQ was not on-site to observe this test due to COVID-19 safety concerns. NC DAQ concludes that
the testing was conducted in accordance to the modified testing protocol submitted by Chemours and
that the analytical results appear representative of the stack conditions and process operations during
the testing except as noted above.
Cc: Central Files--Bladen County
IBEAM Documents-0900009